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ZIMMERMAN v. UNITED STATES

No. 18416.

318 F.2d 611 (1963)

Hans ZIMMERMAN and Clara Zimmerman, Appellants, v. UNITED STATES of America and District Director of Internal Revenue, Appellees.

United States Court of Appeals Ninth Circuit.

June 21, 1963.

Attorney(s) appearing for the Case

Kenneth E. Young, Honolulu, Hawaii, for appellants.

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Robert N. Anderson, Alan D. Pekelner, Attys., Dept. of Justice, Washington, D. C.; and Herman T. F. Lum, U. S. Atty., Honolulu, Hawaii, for appellee.

Before HAMLEY, HAMLIN and DUNIWAY, Circuit Judges.

HAMLIN, Circuit Judge.

Hans and Clara Zimmerman, appellants herein, commenced an action in the United States District Court for the District of Hawaii for the refund of income taxes in the amount of $13,180.66. Their claim for a refund was based upon the refusal of appellees to allow as a bad debt deduction under section 166(a) (1) of the Internal Revenue Code of 1954 (26 U.S.C. § 166(a) (1))1 money allegedly

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